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Comparison

Read two legal systems against each other

Because every portal follows the same fifteen-section outline, the comparison is genuinely like-for-like rather than a collage of whatever each government happens to publish.

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Comparison of selected legal systems
AttributeParaguayReviewedHaitiReviewedLithuaniaReviewedBruneiReviewed
Legal familyCivil lawCivil lawCivil lawMixed common law and Islamic law
System of governmentUnitary presidential republicUnitary semi-presidential republicUnitary semi-presidential republicAbsolute monarchy
ConstitutionConstitution of the Republic of ParaguayConstitution de la Rรฉpublique d'HaรฏtiConstitution of the Republic of LithuaniaConstitution of Brunei Darussalam
In force since1992198719921959
CapitalAsunciรณnPort-au-PrinceVilniusBandar Seri Begawan
Official languagesSpanish, GuaranรญFrench, Haitian CreoleLithuanianMalay, English
CurrencyParaguayan guaranรญ (PYG)Haitian gourde (HTG)Euro (EUR)Brunei dollar (BND)
Population6,900,00011,600,0002,860,000450,000
Division of powersUnitary with seventeen departments and the capital district, each with an elected governor and departmental board holding administrative and limited fiscal competence. Legislative power is national.Unitary with constitutionally recognised decentralisation to 10 departments, arrondissements and communes, and to the communal section as the smallest territorial unit. In practice the elected local bodies are largely unfilled and replaced by appointed interim commissions.Semi-presidential government with a directly elected President focused on foreign and security policy, a Government answerable to the Seimas, and a separate Constitutional Court.Unitary, with four districts administered by district officers reporting to the Ministry of Home Affairs. No federal or devolved tier; village and mukim headmen have recognised consultative functions.
How law is madeBills may start in either chamber and must pass both. The President may object in whole or part; Congress overcomes an objection by absolute majority in both chambers. Constitutional amendment requires a two-thirds vote of each chamber and ratification by referendum; wholesale reform requires a constituent assembly.Under the 1987 Constitution bills pass both chambers and are promulgated by the President, who may return a text once for reconsideration. With Parliament not sitting, measures have been issued as executive decrees since 2020 โ€” a practice widely criticised as lacking constitutional foundation, and a key reason to check the current status of any recent instrument before relying on it.Bills are adopted by the Seimas and signed by the President, who may veto and return a bill for reconsideration.In form, bills are introduced in the Legislative Council and assented to by the Sultan. In practice the significant instruments are Orders made by the Sultan under the emergency proclamation, which take effect on publication in the Government Gazette without Council passage. The Syariah Penal Code Order 2013 was enacted this way.
Legal professionA law degree and registration of the title with the Supreme Court, which maintains the roll and exercises discipline. Bar membership is voluntary. Because both Spanish and Guaranรญ are official, courts must provide interpretation, and practitioners outside Asunciรณn are commonly bilingual.Advocates are admitted to one of the departmental bars (Ordre des avocats), most prominently the Port-au-Prince bar, after a law degree and a period of pupillage. Notaries hold a separate public office with exclusive competence over authentic acts including land transfers, which matters greatly given widespread informality in land title.Advocates belong to the Lithuanian Bar Association; notaries handle property, company and succession formalities.Advocates and solicitors are admitted by the High Court under the Legal Profession Act, generally after qualifying in England, Malaysia, Singapore or Australia and completing local requirements. The profession is small โ€” a few hundred practitioners โ€” and foreign counsel may be admitted ad hoc for particular cases. Syariah practice is a separate track: Syariah lawyers are certified under the Syariah Courts Act and appear only in the Syariah hierarchy, so a matter that crosses both systems needs two sets of representation.

A comparison table flattens nuance by design. Where a difference matters to a decision you are making, open both portals and read the section in full โ€” the constitutional detail behind a one-line summary is often the part that governs the outcome.